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Interpretation Response #99-0169 ([Ultramar Diamond Shamrock] [Mr. George Lewis])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Ultramar Diamond Shamrock

Individual Name: Mr. George Lewis

Location State: TX Country: US

View the Interpretation Document

Response text:

September 15, 1999


Mr. George Lewis                         Ref. No. 99-0169
Measurement Manager
Ultramar Diamond Shamrock
HCR1 Box 36
Sunray, TX 79086

Dear Mr.  Lewis:

This is in response to your letter dated June 23, 1999, concerning the requirements for placarding a vehicle, other than a cargo tank, with up to 60 gallons of flammable and combustible liquid in a non­specification packaging under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask whether placarding is based solely on the weight of the material, or the material plus the packaging (including the hoses and piping).

As provided by § 172.504 (a), a transport vehicle containing over 1,000 pounds aggregate gross weight (packaging plus contents) of a hazardous material covered by Table 2 must be placarded.  In this case, the packaging is considered a non-bulk packaging (capacity of less than 119 gallons) and authorized under the terms of an exemption.  The exemption grants no relief from the placarding provisions of Part 172, Subpart F; therefore, your meter provers containing flammable liquid and/or flammable gas must be placarded.

I trust this answers your inquiry.  If you have further questions, please do not hesitate to contact this  Office.



Delmer  F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.504 General placarding requirements